A new era of private corporation tax rules – Part IV
The new TOSI rules are effective as of January 1, 2018. However, corporations have until the end of 2018 to complete corporate reorganizations to meet the votes and value test in the “excluded shares” exception if that exception is otherwise available to be used. Other points from Bill C-74 will be of interest as well. This article highlights comments from the Canada Revenue Agency and Department of Finance made at the roundtable at CALU and STEP.